Best Judgement assessment u/s 144 - estimation of income @12 or...

Best Judgement assessment u/s 144 - estimation of income @12 or 8% - keeping in mind the judicial guideline available on issue, that after rejection of accounts, the income of the assessee is to be estimated on some reasonable basis for which comparable case and history of the assessee can be taken as a guide - it is fair, reasonable and logical to apply an average rate of two earlier years(@3.5%)